MCU15/0095 & REC15/0022 PM Submission Object - N Asher

precautionary       principle and consider the possible risks to make a decision that is not in any way harmful.
In the absence of scientific consensus that the Development                        is not harmful, the burden of proof that it is
not harmful falls on the Developer and the Property Owner. Neither has satisfied that burden of proof.


Emissions from           petrol     stations    are widely        acknowledged     to contain   compounds         harmful     to health,
including,     toluene,     xylenes; and benzene which is a known                    health risk and carcinogen.            Exposure to
emissions from           petrol   stations      has been shown to be associated with                 increased risks of childhood
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leukaemia, independent              of other risk factors.


A Spanish study published              in the US Journal of Environmental             Management        in December 2010' shows
that emissions from evaporated                   petrol or fuel, generally when petrol is being transferred                 or has been
spilt, contaminates         the surrounding         area with volatile materials, including the carcinogen benzene.                    This
means that the atmosphere                in the immediate          vicinity of service stations can be contaminated               up to SO
metres away.            The study recommends              that a minimum         distance of SO metres should be maintained
between        petrol    stations     and housing,        and 100 metres for "especially            vulnerable"      facilities    such "as
hospitals, health centres, schools and old people's homes.


 In 2014, Dr Ian Francis Musgrave,                   Lecturer in Pharmacology,         University    of Adelaide,      referred      to the
Spanish Study stating that the radius of significant levels of hydrocarbons                         of concern was of the order of
approximately           7Sm from the station.            For example the levels of benzene at 75 meters were 4 "g/m3,
which is 25% of the EPA yearly exposure limit of 16 "g/m'.


Professor Lidia Morawska               at QUT has been conducting              studies in Brisbane into the health effects of
exposure of children to airborne nano and ultrafine                      particles (UFP) emitted      from motor vehicles. Owing
to their small size, UFPs are able to penetrate                       deep into the lungs, where they may cause adverse
respiratory,      pulmonary       and cardiovascular         health effects. Her studies show that the impact is significant
and visible. In addition to the emissions from vehicles in the service station, the proposed Development
will generate more traffic in and around the School. These emission sources are in such close proximity
to the school that they pose and unacceptable                       increased health risk to this vulnerable         population      group
of school students.


The Western Australian              Environmental        Protection    Authority   (WAEPA) in its policy document,                Guideline
for the Assessment of Environmental Factors, recommended                           separation   distances for Industrial Residual
Air Emissions of 200 meters                    between     a service station       operating    24 hours a day and a school.
"Separation       distance" is defined to be the shortest distance between the boundary of the service station
and the School.


The subject Property directly adjoins the School's 14m toddler outdoor                          pool and the 25m outdoor               pool
used by all age groups. The fuel bowsers on the proposed development                                 are dangerously        close to the
Pool facilities     being no more than an estimated                    30 meters from the outdoor          toddler     pool. The pool
facilities,   apart from constant              school use, are utilised all year round by the School's associated Swim


'see e.g. CSteffen et al 2004 - "Acute childhood leukaemia and environmental exposure to potentia/sources of
  benzene and ather hydrocarbons; a case-contra/study" and many other similar studies showing adverse effects
  particularly on young growing bodies.
'Tern~s et al


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